Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Penalty u/s 271(1)(c) - disallowance u/s 40(a)(ia) - The only reason for which the expenditure was disallowed is due to non–deduction of tax at source. In other words, it is statutory disallowance. That being the case, the assessee cannot be accused of submitting inaccurate particulars of income or concealing its income - No penalty - AT
Penalty u/s 271(1)(c) - disallowance u/s 40(a)(ia) - The only reason for which the expenditure was disallowed is due to non–deduction of tax at source. In other words, it is statutory disallowance. That being the case, the assessee cannot be accused of submitting inaccurate particulars of income or concealing its income - No penalty - AT
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